Wednesday, 25 November 2015

Schrödinger's Oats

Labelling-wise, gluten is not an allergen - as I wrote a month ago - but oats are.

Oats are one of the 'cereals containing gluten' as defined by the EU. They were included because they are normally contaminated with wheat flour, not because they intrinsically contain gluten. They contain avenin, a protein most coeliacs seem to be able to tolerate in modest doses, but 5% of whom may not. Nevertheless, oats are on the official list of allergens - and have been since a 2003 Directive.

Because of this, oats must be emphasised on labelling, in accordance with EU FIC 1169/2011, which came into full effect December 2014. ("14 allergens" law.)

A separate law - Commission Regulation 41/2009, effective since 2012, on the labelling of gluten free food - specified that oats could be labelled gluten-free if produced free from wheat contamination - at least to levels below 20 parts per million (20ppm) required by law.

Neither of these laws 'trumps' or over-writes the other. The first is about allergens present; the second is about gluten 'absent' - and is not an allergen law.

Although 14 allergens laws allow some labelling exemptions with regards to cereals containing gluten ...

... they only include glucose syrups, maltodextrins and distillates - as you can see - not gluten free oats.

An oat is a 'cereal containing gluten' - even when it's a gluten-free oat - because no law has decreed it otherwise.

And the consequence of that apparent paradox is this: a gluten free oat still has to be highlighted as an allergen on labelling.

It's not perfect, but the best confirmation of this I've found is from the FSAI. Scroll down to "How should gluten-free oats be labelled in a list of ingredients?"

Coeliac UK also acknowledge the correctness of emphasising all oats, regardless of GF status, in this question on their site.

So who's not emphasising - and who is?
I've contacted a selection of the free-from oaty producers with this question on and off over some months. This hasn't always gone down well. Of the responses I've had (not many), none would tell me who advised them on oat labelling.

This is not to name and shame, but inconsistency is confusing the consumer, so examples are important. The following are drawn from my own labelling inspections, that of bloggers, and the few responses received. My research was by no means exhaustive; I've not contacted many manufacturers.

Not emphasising ... 
Nairn's are not emphasising their GF oats - although they said that "as some coeliacs are also intolerant to the protein avenin which is found in oats we do highlight this on our packs".

Neither are Rude Health (who told me they'd correct this if needs be, and I have to compliment them on their willingness to discuss the subject earlier in the year openly on social media).

Neither are Perkier. Trek bars, no. Nature's Path, no. Bioglan, no. Neal's Yard Wholefoods, no. Windmill Organics (Amisa, Biona) told me "gluten free oats are not an allergen", so I presume they don't.

Emphasising ...
Morrison's, earlier this year, were doing both, but I checked last week and they've now got it right on almost all products - except their mixed granola, which oddly was wholly non-compliant with new regulations, and still had a 'contains' box.

Tesco products looked correctly labelled (see cookies above). Waitrose, Delicious Alchemy and Prewetts Biscuits too.

Udi's used to not emphasise, and told me several times that was correct. Some months ago, they quietly changed and now do.

I'm particularly impressed when small brands get it right. Take a bow, Most Marvellous Baking. (Page from their site shown below.)

What's the solution?
Because around 5% of coeliacs can't tolerate oats, and a few rare individuals are oat allergic, they should remain an allergen.

To me it's obvious: redefine oats as not being a cereal containing gluten, and make it an allergen in its own right, rather than within a group containing its cousins wheat, barley, and rye.

Manufacturers using oats would still need to emphasise this 15th allergen - but also add a precautionary warning - 'contains wheat traces' - when using non-GF oats. If oats are naturally free from gluten, should we not be working on the premise that they are GF, unless declared otherwise - and not the other way around?

As for the confusion surrounding emphasising, I guess that's one for the FSA to advise on and help resolve. To my knowledge, they have not issued any guidance, advice or statement specific to this particular query of emphasising gluten free oats on labels.

Tuesday, 24 November 2015

Three Months: Quick in Daily Mail World

You may remember the brouhaha in August when the Daily Mail claimed the NHS spent £116 million on prescription 'gluten-free junk food'. It screamed 'Doughnuts and Pizzas on the NHS' - if you're a coeliac and can bear to be reminded of it.

Well, three months on, lo and behold - and more than I expected, I'm happy to admit - they have issued a correction which you can read here, which acknowledges the hugely over-inflated figure was wrong (it was wrong by a factor of almost 100, as I suggested in a previous blog).

There's even an apology to members of the coeliac community "for any distress they may have been caused".

There's no apology to the coeliac community for the short term and long term damage done to their ongoing campaigning to boost awareness of the disease and the importance of accessible gluten-free options for all who most need them.

Three months. Maybe it was just a one-off? Maybe it fell to the bottom of the in-box and was forgotten about?

Or maybe not. The same thing happened four years ago. In July 2011 the DM reported that the NHS were spending over £30 on a gluten-free loaf (story no longer on their site). It wasn't until October 2011 - yes, three months on - that they admitted it actually cost £2.82. You can still read that here.

On that page the DM describes its then new 'correction and clarification' column as a page which "provides an opportunity to correct ... errors quickly".

Comedy gold, Daily Mail.

Monday, 23 November 2015

CAMRA, Confusion and Cocoa

Last Monday, 16th November, the Independent published an article - CAMRA: UK's biggest organiser of beer festivals refuses to stock ales from breweries that don't provide full list of ingredients. The paper billed the move by CAMRA (The Campaign for Real Ale) as a support for those with food allergies and intolerances.

On the same day, I received a press release from CAMRA embargoed until Friday 20th and which featured the same news. On that date, Hospitality and Catering News reproduced it in full.

You might consider it admirable to insist all breweries should provide full ingredients. But it's important to note that this is NOT a legal requirement, unlike the requirements placed on foods and most other drinks. Alcoholic drinks above a certain strength are exempt from listing full ingredients, but they must disclose any of the 14 allergens present.

"Every CAMRA festival now has full allergen information [my emphasis] available to customers for every single real ale on sale, which ensures that somebody with an intolerance to something like gluten or wheat can be sure the beer they are choosing is suitable for them to drink," Tim Page, CAMRA CE, is quoted as saying on the press release.

But hang on, is this about just the allergens - or all ingredients? It is not entirely clear. Providing full allergen information is just ... the law. We don't see supermarkets trumpeting the fact that all the foods on their shelves give full allergen information ... because that's just the law too.

The press release goes on to quote Lindsey McManus of Allergy UK complimenting CAMRA for ...  upholding the law, then throws in some exaggerated figures for dairy intolerance (33%), gluten allergy (6%) and gluten intolerance (20%) (no clue where these figures come from; no reference provided), quotes some brewers, and ends with another puzzling quote from Page.

" ... It's important that brewers are making allergen info readily available - brewing with raspberry, cocoa and milk sugars? Sounds delicious, but ensure your customers know about it!" 

Neither raspberry nor cocoa are allergens. Do CAMRA know what they're talking about, or even asking for, I can't help wondering?

Allergens or Ingredients?
I spoke with CAMRA's press officer - a conversation which didn't fill me with much confidence that the difference between food allergens and full ingredients was understood at CAMRA. Ayo eventually confirmed that 'we will not be accepting beers from ... breweries that can't provide a full list of ingredients ... but will be encouraging brewers to provide this information'.

Some will argue the law should demand all ingredients be declared, to help those allergic to ingredients not among the 14. A fair point, but if that's what CAMRA is insisting on, then they may risk pissing off those breweries who want to keep their full ingredients a trade secret - a privilege the law currently entitles them to, whether you, I or they approve of it or not.

And if this is indeed what CAMRA is calling for, then let's also be clear that demanding full ingredient transparency is nothing whatsoever to do with abiding by new EU allergen labelling regulations. In fact, it's somewhat of the opposite: it's demanding information on ingredients which fall outside the regulations.

All this is a shame. But I'm so baffled by this whole business that I'm left uncertain whether this really is what CAMRA is asking for. The comically bullish title of the press release - 'CAMRA Tackling New Allergens Laws Head-On' - begs further questions on their understanding. But I guess 'CAMRA will not break the law nor endorse law breaking' wouldn't have made much of an impact.

Sunday, 15 November 2015

New Guidance on Free-From Allergen Claims

The British Retail Consortium and the Food and Drink Federation, in partnership with Coeliac UK and the Anaphylaxis Campaign, have issued a new guidance document to manufacturers and caterers on making 'free from' claims. You can read it here.

Key guidance includes information on being able to substantiate a 'free from' claim of source ingredients, strict control for cross-contamination, and - where appropriate - robust sampling and testing of foods. The importance of risk assessment is strongly emphasised.

I like that the document clearly conveys the sense that a 'free from' claim is a serious matter when it comes to allergies and intolerances (claims relating to being free from preservatives, additives, animal ingredients etc are not within its remit).

Although gluten is not an allergen, 'gluten free' is the only key 'free from' term which we have a definition for - 20 parts per million of gluten maximum. In the absence of threshold levels for the 14 allergens, 'free from' - the document makes clear - must mean 'no detectable allergen' (according to the best analytical testing methods).

The lowest detectable level of gluten is 3ppm, and so the 20ppm threshold essentially raises the bar and gives manufacturers some leeway (the figure was set not because of this, but because it was thought a safe level for the vast majority of those with coeliac disease).

But the lowest detectable level of the whey protein beta-lactoglobulin is 0.01ppm - according to Dario Deli of Romer Labs - so I can only guess at the difficulty of meeting this extreme trace level for brands who do handle milk. Will this result in a reduction in the use of dairy/milk free claims?

On that subject, I felt it a pity that the guidance didn't address 'dairy free' versus 'milk free'. The BRC press office told me that "there has been a strong move in the market from dairy-free claims to milk-free claims" - which is good, as I think it's needed - but I've not seen much evidence for it. Has anyone?

I found the key summary statement that "A 'free from' claim is an absolute claim unless a regulatory threshold has been set" inaccurate. An absolute claim, for me, is black or white. Gluten Free is 20ppm or below. Not gluten free is above 20ppm. The line has been drawn far lower for all other allergens - at their respective 'no detectable' levels, whatever they may be, and they are never zero - but it's still a line, and that line eliminates any sliding scale when it comes to 'free from' messaging, essentially creating absolute states. A food or drink either is or isn't 'free from' an allergen - according to this guidance - there's no 'fairly free from' or 'virtually free from' to be had. See an older post of mine - Gluten Free is Dead - that explores this idea more fully.

The final thing to catch my eye was the reminder to manufacturers to not make a 'free from' statement on a product if that 'free from' claim can be made on all such similar products. This is actually enshrouded in a law (EU FIC 1169/2011 Article 7) that states you cannot claim a food possesses particular characteristics when all similar foods possess the same characteristics. Therefore, manufacturers can't use 'gluten free' on a bottle of water. My packet of Uncle Ben's Wholegrain claims to be 'gluten free', but as all pure rice is GF, that would make this dear old fellow above a law-breaker ...

Someone tell me it isn't true?

Wednesday, 11 November 2015

Healthy Snacking by Boots

Earlier this summer I came across the display below in a branch of Boots local to me.

Under 'healthy snacking' are stocked Tasty Little Numbers jelly beans, fruit-flavour chews by Fruitella, Udi's bagel chips, TLN biscuit bars, Sweet Freedom 'Choc Shot', Mentos and more. 

A month ago, I approached Boots PR team about it, and asked for an interview with a nutritionist or other appropriate spokesperson. I was invited instead to submit questions by email. Twice I asked whether an interview was possible, but the request to submit by email was repeated. I submitted one question. 

It was this: Given the country's obesity crisis, how can Boots justify stocking jelly beans, biscuit bars, chocolate and chips under a 'Healthy Snacking' banner? 

Ten days later (my initial contact left), the answer came:

"As a responsible retailer, we believe that we have a role to play in helping our customers to lead a healthy lifestyle. We believe in providing options for a healthy and balanced diet, offering snacks such as fruits, nuts and seeds, as well as confectionary and treat items such as chocolate and biscuits. It's important to note that products sold within our healthy snacking range and the Tasty Little Numbers brand are all within a portion controlled offer and are under 100 calories per portion"

I asked whether the quality of being calorie-controlled determined whether or not a product could be included in the Healthy Snacking section.

"We think it's important to offer options for a healthy and balanced diet"

I pressed again - what were the determinants? Where does Boots draw the line? I asked for an example of a food sold not deemed suitable for 'Healthy Snacking'.

"We are committed to supporting our customers healthy diet and lifestyle choices. Our current food range aims to offer healthier alternatives, which also include some 'treat' items. All products sold within our healthy snacking range and Tasty Little Numbers are within a portion controlled offer ... and can therefore be included as part of a balanced diet"

I tried yet again - now with a different contact. So a Mars bar would not qualify, because it is more than 100 calories? How do Udi's Bagel Chips (700 calories) fit into this?

"At Boots UK we aim to offer healthier snack alternatives to help our customers achieve a balanced diet. We aim to make our signage and merchandising clear to our customers so that they can easily navigate our snacks and make informed choices"

That last response was yesterday, four weeks after my initial approach. Having lost the will by this point, I reiterated my questions, and my request to speak with someone, giving Boots till the end of the day to reply.

They did not reply. 

Free From is healthier - or is it?
There are many free from brands included in the display (including some whose presence I wouldn't quibble with, such as Bounce, 9Bar or Nakd). In fact, I can identify only a few not considered a free from brand by at least some in the allergic, intolerant or coeliac communities. 

Having failed to obtain any specific answer from Boots to account for this boggling display of products marketed as healthy - including those Udi's Bagel Chips (Cinnamon and Sugar), which are 18% fat and 22% sugar, and (now that I've done my maths properly), almost 800 calories a box - I have to wonder whether in fact it's simply by virtue of their gluten free (or other free) status. It's the only explanation I can come up with, as I just don't buy their 'portion controlled' argument, which the bagel chips box makes a mockery of anyway. 

If true, then Boots, worryingly for a company of their standing, would have fallen for one of the most common misconceptions which the 'free from' boom has spawned - that of necessarily improved nutritional product profiles. 

Whether that's the case or not, what seems undeniable is this: here is a national pharmacy chain, popularly trusted as a provider of reliable healthcare products to the nation, which is marketing confectionary, biscuits and calorific chips as foods which are good for you. 

Surely this can't be right?

Postscript, 20th November 2015: 
Ten days on, I nipped into my local branch to discover the addition of bags of Maltesers to Healthy Snacking section. Here's the evidence.

Thursday, 29 October 2015

The allergy fakers aren't all allergy fakers

A quick post about the article 'Why Food Allergy Fakers Need to Stop' - published a couple of weeks ago, which proved a massive hit on social media among many coeliacs and food allergics - and its follow-up of sorts, published just a few days ago, 'How We Made Gluten into a Monster'.

The first piece is a long read, so set aside some time for it, but it is worth it, as it takes in the history of food hypersensitivities and looks at where we got to where we are today - on many levels, not solely on the underlying theme of the article, which is 'free from' catering in food service.

Essentially, it's a customer plea, echoed by many in the catering industry, to only claim an 'allergy' or severe intolerance in a restaurant, if you genuinely have a medically diagnosed condition - given it's more work for catering staff to accommodate 'free from' requests. Faking it, the writer argues, undermines genuine sufferers, and fed up food service managers who feel like rebelling against the faddists may end up withdrawing offers to cater free-from, which will only end up punishing those who need the services most.

The piece - mostly on account of its headline, I suspect - was widely welcomed on Facebook and Twitter, but it's worth remembering that it's the 'fakers' (or faddists, or lifestylers) who have mostly driven the rise in free from, particularly on-the-shelf products. We have a far greater choice in the supermarket, largely thanks to them.

While I agree that claiming a gluten sensitivity in a restaurant and later ordering the profiteroles as a special treat is the sort of behaviour to be called out and criticised, I have to wonder why it's such an issue to some chefs whether a request is either genuine or 'faked'. If you're offering gluten-free catering in a restaurant, can you really complain simply because it becomes too popular?

But my key concern about the reaction to the piece is that not every 'free from' diner falls neatly into the 'genuine' / 'faker' dichotomy. What about those who sincerely think they're made ill by a food, and who have had no support from their healthcare providers? They could be wrong, for all we know, but perhaps they are right, or perhaps they have a psychologically-rooted problem with food of which they are completely unaware. Do they deserve to be dubbed 'fakers'?

I've said it many times that I don't think self-diagnosis is wise or reliable, but my main issue with the self-diagnosed is specifically with those who then evangelise about (usually) gluten-free, and encourage others to follow their lead, typically on the back of having read the widely discredited Wheat Belly.

On the other hand, I have real sympathy with those who feel unwell, and can't get answers, and whom the media typically like to tar with an 'all in the head' brush.

Let's not forget them, please. Not all are faking it for attention or for weight loss.

Sunday, 25 October 2015

Is joking about incurable disease the new black?

Imagine a world where "Chronic obesity is the new black" was a signpost to WeightWatchers ready meals.

Or perhaps "Diabetes type I is the new black" was the slogan accompanying some sugar-free chocolate.

I wonder whether we're a step closer to such crassness after this was posted on Twitter yesterday by a clearly unimpressed Miss Doozer.

The food service outlet in question is called UGOT, and the picture is from Newcastle station.

Others added to Miss Doozer's dissent. To his credit, UGOT's founder Joe addressed it at once. He wrote: "I am a 22 year old with gluten intolerance who created this brand to allow others who share in my frustration at the lack of a healthy & accessible variety of gluten free products [sic] and hopefully make light of a somewhat challenging situation".

Lorna Kellett argued that it reinforces the "dangerous beliefs in the catering industry that all people are GF mainly because it's trendy".

I fear she's right. I fear it plays into the hands of sceptics who from time-to-time go on the attack at those on restricted diets.

It's important to point out that UGOT received possibly as much support as criticism: some have argued that the sign raises the profile of coeliac disease - and even I have to acknowledge that this certainly does help bring the word 'coeliac' into the mainstream, which might not be such a bad thing. "I don't think this is the easy road for companies and (they) should be supported," said Danny Hughes.

I think 'Gluten free is the new black' might have been acceptable to many. The line implies gluten free is fashionable or faddy. And it is. Many without any gluten-related disorder use gluten free as a method for weight loss, one which is not recommended by dietitians and has no evidence in support of it - and that's the definition of a fad, right there.

But coeliac is an autoimmune disease, with no cure. I wonder whether this may backfire for what seems to be a young company, who look to be offering some terrific free from options at a location where many 'on the go' coeliacs and other food sensitives may really need them.

"We are trying to give a platform to encourage those with intolerance to embrace it and allow them to live a tastier lifestyle," UGOT told another objector.

I'm not sure over-intellectualising something as relatively straightforward as providing food to people who want to buy food really helps their cause. I'll stick my neck out and suggest that coeliacs - who have more than a mere 'intolerance' - don't particularly want a platform on which they can embrace their food sensitivity. They just want to have tasty, healthy and safe options when going about their business like everybody else.

Meet that need well, UGOT, and it'll be you who is the new black.

Wednesday, 21 October 2015

Gluten and dairy are not allergens

The list of 14 allergens can be seen here. Gluten and dairy are not on it.

But gluten-containing cereals and milk are.

This is not a trivial distinction.

Tesco currently have a milk free section and a separate dairy free section on their website. At the time of writing, you can see it here. Twitter user Andrew questioned Tesco on the difference between the two, and received a two-tweet response which made little sense.

If you choose 'milk free' you get to a page whose title bar reads 'lactose free' and a section divided into four-subsections - Bakery, Store Cupboard, Treats & Snacks and ... Dairy. This also makes no sense: dairy products under a milk free category? There's also a dairy section under the dairy free category.

The good news is that Tesco agreed that this was a problem, and have told me they're addressing it. But this just adds to a long-held concern about our using the word 'dairy' in allergy conversation: it's not a clearly defined or understood term, and I suspect that it leads to problems such as this one. I've seen 'dairy free' applied to foods free of cow's milk, but containing goat's or sheep's - but 'milk' - the actual allergen - incorporates all mammalian milks.

Should we abandon 'dairy free' and stick only to 'milk free'? It is milk which has to appear on the ingredients label, after all. I'm beginning to think we should. If allergen thresholds are ever introduced, surely we will need to?

Naturally, I don't feel we should abandon 'gluten free' - the most important two words in any coeliac shopper's vocabulary - but not every manufacturer or consumer understands that it is the grain which is the allergen as far as the regulations are concerned - not the gluten.

This means it is 'wheat', 'barley', 'rye' or 'oats' which should be highlighted in lists of ingredients - not 'gluten' (see Clause 30 here). Marks and Spencer do not appear to have received both parts of the memo.

Because of this, remember that food service outlets aren't obliged to tell you that there is gluten in a dish per se - they're obliged to tell you that there is wheat, rye, barley or oats in a dish - from which you will almost always be able to confirm that there is gluten present.

Yes, it's confusing, but gluten-related labelling law and '14 allergen' law are distinct, and don't necessarily work together perfectly. This is a particular problem when it comes to the special case of oats - and I'll be blogging about this next ...